Speech – "Preventing Fatigue is a Joint Responsibility"

ALPA Flight and Duty Symposium

Thank you, Captain Moak. It’s great to be here today. When I spoke last month at ALPA’s safety conference, I noted that I’ve had the chance to work with ALPA in various capacities for the last two decades now, starting in the early 90’s at TWA when I represented a pilot in a certificate action brought by the FAA. It’s good to be back among friends. In my new role, I want to thank ALPA for the great work you do and for being a solid partner with us in efforts to enhance aviation safety. Your professionalism is an essential component of what we do and I think this conference is a testimony to that.

The FAA manages safety and risk much differently than it did 20 years ago. We are now about to embark on a sea change in how we schedule flight and duty time. I know everyone’s gearing up, and this conference has been timely in that regard. I’m pleased with the significant participation here of the airlines, operations folks, pilots, scheduling vendors and others. I know you’ve had an informed discussion the past couple of days of what the rule entails. I’ve heard from several sources that it’s been lively and engaging.

This is a milestone in our safety efforts. We are using a science-based approach to addressing fatigue. We are taking into account the body’s 24-hour clock and how flight operations impact the body’s natural rhythms. The United States is leading the world by introducing these concepts and we hope other countries will adopt this approach as well, creating an improvement in safety globally. In fact, we’ve been working with ICAO for the last three years to develop standards, guidance and recommended practices that can be used by other civil aviation authorities around the world. We’re also working with our counterparts in Europe to offer guidance in implementing this science-based approach among European carriers.

Pilot fatigue has been an issue since the early days of flight. Charles Lindbergh famously described the fatigue he felt on his historic flight across the Atlantic more than 85 years ago.

“My whole body argues dully that nothing—nothing life can attain—is quite so desirable as sleep,” he later wrote.

Lindbergh felt sleepy nine hours into his 33-and-a-half-hour flight. He stomped his feet on the floor boards, shook his head and flexed the muscles of his arms and legs. In the eighteenth hour, he rubbed the muscles of his face. In the twentieth hour he realized he’d been asleep briefly with his eyes open. He wasn’t sure if he was dreaming or awake.

I have had similar experiences driving an old beater across country as a teenager in the 1970s. I suspect most of us in this room have had some experience of that type of fatigue. But our understanding of fatigue and sleep has advanced and evolved over the years. The limits set in this rule – for flight time, overall duty, and for rest – incorporate the latest in fatigue science.

But we’ve also addressed the need airlines may have for flexibility. If a carrier wants to propose an alternate approach, they may use a Fatigue Risk Management System to prove scientifically that this alternate approach will not induce fatigue. Carriers will have an opportunity to provide the data showing there is an equivalent level of safety.

The success of this rule boils down to the fact that preventing fatigue is a joint responsibility. It is the responsibility of both the airline and the pilot. The airline provides an expanded opportunity for rest. And the pilot has the responsibility to take advantage of that window and get the rest he or she needs. Pilots need to examine their lives at work and at home and consider activities and commutes which could contribute to fatigue. Pilots are going to have to sign a release before every segment, saying they are fit for duty. And if a pilot is fatigued, the airline must remove him or her and allow the pilot to rest.

Pilots and airlines have to work together to address any issues around fitness for duty. There should be no punitive action for assessing one’s fitness for duty or determining that you’re just not up to flying that day. If you’ve done too many long-hauls; if you’ve been shooting low minimums all day; if you’re flying into extremely busy airports – all of this can add up and you need to assess it. This entire process is designed to prevent fatigue from becoming a factor in performance.

There is a companion piece of legislation that goes hand in hand with this flight and duty rule, and that is the requirement for carriers to have a Fatigue Risk Management Plan. These plans apply to both passenger and cargo operations and provide a way for pilots to report fatigue issues as they encounter them. We rely on your professionalism to report any problems.

If a trip induces fatigue, pilots can and should report it. If a rest period is always during the daylight hours and it’s hard to sleep for days in a row, this could induce fatigue. A pilot should report it. This is a voluntary reporting tool that I hope you will use. There is no punitive action related to these reports. Again, you are on the front lines of safety and it’s up to you to help make it work.

The flight and duty rule is only one part of our effort to enhance safety. The FAA continues to spend a considerable amount of time and effort on rules related to human factors. We may have new, sophisticated aircraft and great new systems, but if we do not have properly rested, experienced, and trained crews, we won’t achieve the level of safety we always strive for.

Last week, Secretary Foxx, Deputy Secretary Porcari and I met with the families of Colgan Air Flight 3407. There is nothing that reinforces the importance of our safety mission more than meeting the families of the victims of a crash and hearing their stories. The families have become effective and very important advocates for these enhanced safety rules. We learned many lessons from that crash in February, 2009, and have incorporated safeguards into our system to strengthen it.

In addition to the flight and duty rule, the FAA just released the final rule on pilot qualifications. The new rule increases the qualifications to be a first officer for a U.S. airline. These first officers will now be required to have an ATP certificate, with 1,500 hours of flight time, just like a captain. And all applicants for an ATP will have to complete new FAA-approved training to ensure the pilot has the proper qualifications and experience to fly for an airline.

The rule does allow first officers to have a restricted ATP with fewer hours if they come from the military or have a college degree based on an approved aviation curriculum–but they won't get the full privileges of an ATP until they meet the 1,500 hour requirement.

We’re also requiring that first officers have a type rating with additional training and testing specific to the airplanes they fly. And co-pilots will need a minimum of 1,000 flight hours in the right seat before serving as a captain for a U.S. airline. This will help mitigate the risk of a first officer transitioning to captain before he or she is ready. The rule ensures that first officers have a stronger foundation of aeronautical knowledge and experience before they fly for an air carrier. ALPA supported all these improvements, and that helped move this project through the process.

Training is fundamental, and I’m sure you are aware that we’re expecting to release the crew training rule in October. That is a complicated rulemaking project – one that, again, ALPA has supported by providing important comments, which again helped us develop a better final rule. This rule will expand upon the strong foundation we have built already for pilot training. It will address real risks we all know can and should be addressed in training – so that pilots are prepared to respond when faced with emergencies. We want pilots to have sufficient knowledge, experience and confidence so they can appropriately handle any situation.

Finally, one of my pet issues is general aviation safety. We want all pilots to have the best training and skills, and that includes general aviation pilots. Over the last five years, we’ve seen our GA accident rate fluctuate, but it’s not steadily improving as we would like to see. Forty percent of fatal GA accidents are due to loss of control in flight – mainly stalls. Or, pilots simply don’t pay attention to the basics – like checking fuel prior to takeoff, or trying to beat weather. I know many of you here – and other ALPA members – are active in general aviation. I want to ask you to engage fully in this issue – to reach out to your fellow GA pilots and stress the need to pay attention to basics for example, by signing up for FAA safety seminars or participating in type clubs.

You as pilots and operators have an enormous impact on safety–including your influence in the general aviation community. A lot of this comes down to the basics: to following procedures all the time, even when no one is watching. We rely on your professionalism to continue to improve the system, and we appreciate the dedication and passion you bring to the effort.

With that being said, I don’t want to fatigue this audience unduly, as the afternoon circadian low starts around 1:30 p.m. I encourage you to drink that coffee, and if there are any questions on your mind, speak up and I’ll be happy to answer them.